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Pastimes : Clown-Free Zone... sorry, no clowns allowed
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To: Joan Osland Graffius who wrote (150358)2/9/2002 10:37:25 AM
From: Logain Ablar  Read Replies (1) of 436258
 
Hi Joan:

A problem with a Bermuda holding company structure like TYC is it can't spin off subsidiaries tax free to shareholders like US domestic companies can. Its similar to the tax event where Ingersol Rand just converted to a Bermuda holding company to avoid the US tax on world wide income. The new Ingersol Rand stock exchange was a taxable event.

Just in reverse. The US only allows tax free when its US assets (i.e. US company shares of stock).

Tim
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